Transfer Pricing Documentation & Form 3CEB

Contemporaneous, defensible documentation prepared to the standard required under Rule 10D — never reconstructed after the fact.

Overview

Why documentation quality matters more than the filing itself

Form 3CEB is a statutory filing, but it's only as strong as the underlying Local File and TP study report behind it. Tax authorities and appellate forums give far more weight to documentation prepared contemporaneously — in real time, as transactions occur — than to files assembled after an audit notice arrives.

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Who this applies to

Any Indian entity with international or specified domestic transactions with associated enterprises exceeding the prescribed thresholds.

What We Cover

The full documentation package

Local File / TP Study Report

Entity-level functional, industry and economic analysis under Rule 10D.

Form 3CEB

Statutory Accountant's Report, certified by a Chartered Accountant and filed on time.

Intercompany Agreements

Policy documents and agreements aligned with actual conduct.

Annual Refresh

Roll-forward of documentation each year as transactions and financials change.

Our Process

A structured, calendarised approach

Step 1

Transaction Mapping

Identify every related-party transaction subject to documentation.

Step 2

Functional Analysis

Document functions, assets and risks for each entity.

Step 3

Benchmarking & Drafting

Complete comparability analysis and draft the Local File.

Step 4

Certification & Filing

Obtain Form 3CEB certification and file well before the deadline.

Why Work With Us

Documentation built to be read by a TPO, not just filed

Contemporaneous by Design

A calendarised process, not a last-minute scramble.

Senior Partner Review

Every file reviewed by a senior Chartered Accountant before filing.

Audit-Tested Format

Drafted with an eye toward how it will read to a TPO.

FAQs

Common questions

When is Form 3CEB due? +

Generally on or before 31 October of the relevant assessment year, ahead of the income tax return filing deadline for entities with international/specified domestic transactions.

What happens if documentation isn't maintained? +

Penalties of up to 2% of the transaction value can apply under Section 271AA, in addition to any tax and interest arising from a subsequent TP adjustment.

Need this year's Form 3CEB and Local File prepared?

Book a free consultation before the deadline.